# Storer v. Brown **Status: stub — expand.** **415 U.S. 724 (1974).** The Court upheld California's requirement that an independent candidate not have been registered with a qualified party within a set period before filing. The disaffiliation rule — the "sore loser" provision, now in force in roughly 45 states — survived First Amendment challenge as a legitimate means of preventing the general election from becoming a rerun of a lost primary. The case is also the source of the "reasonably diligent independent candidate" inquiry courts use to assess whether a signature requirement is achievable in practice rather than only on paper. It sits at track 1d of [[How a Candidate Gets on the Ballot]].